Governance of climate change policy:

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Governance of climate change policy:

A case study of South Africa

Alina Averchenkova, Kate Elizabeth Gannon and Patrick Curran

Policy report

June 2019

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The Centre for Climate Change Economics and Policy (CCCEP) was established in 2008 to advance public and private action on climate change through rigorous, innovative research. The Centre is hosted jointly by the University of Leeds and the London School of Economics and Political Science. It is funded by the UK Economic and Social Research Council. www.cccep.ac.uk The Grantham Research Institute on Climate Change and the Environment was established in 2008 at the London School of Economics and Political Science. The Institute brings together international expertise on economics, as well as finance, geography, the environment,

international development and political economy to establish a world-leading centre for policy- relevant research, teaching and training in climate change and the environment. It is funded by the Grantham Foundation for the Protection of the Environment, which also funds the

Grantham Institute – Climate Change and Environment at Imperial College London.

www.lse.ac.uk/GranthamInstitute

About the authors and acknowledgements

Alina Averchenkova is a distinguished policy fellow and the lead for the Governance and

Legislation research programme at the Grantham Research Institute and CCCEP. Kate Elizabeth Gannon is a research officer in the Sustainable Development research team at the Grantham Research Institute. Patrick Curran is a policy analyst and advisor to Professor Nicholas Stern at the Grantham Research Institute.

This research is supported by the British Academy’s Sustainable Development Programme, SDP 2016. The authors further acknowledge financial support from the Grantham Foundation for the Protection of the Environment, and from the UK Economic and Social Research Council through its support of the Centre for Climate Change Economics and Policy.

The authors are grateful to the 30 government officials, politicians, industry stakeholders and policy experts who participated in the formal interviews for this study. Their insights inform the core of this report. We are also grateful for comments and feedback from Emma Archer, Jonathan Barnes, Declan Conway, Kathy Hochstetler, and Richard Perkins, as well as to Michal Nachmany and Joanna Pardoe at the Grantham Research Institute for their valuable logistical and technical support in the design of this study.

Georgina Kyriacou edited and designed the report.

The authors declare no financial relationships with any organisations that might have an interest in the submitted work in the previous three years and no other relationships or activities that could appear to have influenced the submitted work.

This report was first published by the Grantham Research Institute on Climate Change and the Environment and the Centre for Climate Change Economics and Policy in June 2019.

Suggested citation: Averchenkova A, Gannon KE, Patrick C (2019) Governance of climate change policy: A case study of South Africa. London: Grantham Research Institute on Climate Change and the Environment and Centre for Climate Change Economics and Policy, London School of Economics and Political Science

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Executive summary

South Africa has a sophisticated climate governance system but faces a range of challenges

South Africa has put in place one of the most elaborate and consultative climate governance systems observable among developing and emerging economies. As the country moves to implement its national climate goals and ramp ambition to meet the Paris Agreement it faces important domestic challenges that need to be addressed. These challenges are diverse in nature: some arise from overstretched human and technical capacity. Others result from structural issues, such as historical tensions between the main players, lack of clarity in the assignment of responsibilities, lack of ownership over implementation agendas, multiple

ministries dealing with issues concurrently without sufficient coordination, and cumbersome and ineffective communication practices.

These challenges have been exacerbated by a wider political context of several years of political crisis and ‘state capture’ over the past 10 years, which resulted in uncertainty over the direction of climate change and energy policy, distracted leadership and low political will to act further.

Based on extensive expert interviews and the analysis of the key policy documents, the study examines the governance challenges and identifies opportunities for addressing them to enhance implementation of climate policy. While some of the governance challenges, such as those around tensions between the state and private sector, are relatively more important in South Africa than in some other countries owing to its history and recent political dynamics, most issues are also relevant to other emerging and developing economies

Key cross-cutting strategies on climate change are in place, but policies are not aligned and implementation has been delayed

National climate change governance in South Africa is the product of more than two decades of policy evolution and has been shaped by an elaborate landscape of executive policies, strategies, regulations and institutions. The 2004 National Climate Change Response Strategy, followed by the National Climate Change Response White Paper (NCCRWP), approved in 2011, form the foundation of national climate policy. In 2012 climate change became a key element of the National Development Plan, the overarching plan for the country.

While there are a number of policies that operate across multiple sectors, there are also those that are targeted at avoiding emissions or supporting more specific sectors. The development of these sectoral level policies in South Africa is skewed by the greenhouse gas emissions profile of the country, with high-emissions sectors such as energy having more developed climate policy landscapes. These strategies are cross-cutting and gave a start to several specific policy mechanisms, including the Renewable Energy Independent Power Producer Procurement

Programme (REIPPPP) and the cross-sectoral carbon tax. However, since 2010/11 climate change policy overall and, in particular, mitigation policies in the energy sector, have been delayed.

Polices on adaptation and resilience have had little focus to date. A draft National Climate Change Adaptation strategy was released in 2017 for public comment but has not yet been approved.

A systemic issue that could become a roadblock for the implementation of South Africa’s nationally determined contribution (NDC) to the Paris Agreement is the lack of alignment and policy coherence: in other words, the gap between climate change goals and the objectives set in other key strategies and policy documents that determine the trajectory of development. This lack of alignment was particularly important for the period 2010 to 2018 in the case of the Integrated Resource Plan (IRP), which determines South Africa’s strategy for energy generation for the next 20 years. It is also relevant for other sectoral policies, including the Industrial Policy Action Plan and others.

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Horizontal and vertical mechanisms for climate change governance are comprehensive but their effectiveness has varied

Technically, South Africa has a comprehensive system for vertical and horizontal coordination.

The NCCRWP recognises that to ensure sustainable development and a just, managed transition to a low-carbon society, policies need to be aligned both vertically (from national to local levels) and horizontally (between national departments). It sets out an obligation for all government departments and state-owned enterprises to align their policies, strategies and regulations.

The Inter-Ministerial Committee on Climate Change, Intergovernmental Committee on Climate Change and the Forum of South African Directors General are the key mechanisms for

coordination. Every climate change-related policy must further pass through a comprehensive stakeholder engagement process, including through the National Committee on Climate Change and the National Economic Development and Labour Council.

However, ensuring coherent policy formulation and implementation remains challenging due to the fragmented nature of responsibility for climate policy. Clear relationships between different governance elements are not well established and in some cases this has led to a lack of clarity surrounding how policies will be jointly implemented and aligned. The lack of aligned position impacts the effectiveness of the public sector in producing and implementing climate policies and also impedes engagement with and policy signalling to other stakeholders, especially the private sector and investment community.

Limited public sector capacity and dedicated financial resources hamper climate change governance

There is a shortage of capacity to deal with climate change and related policies within the Government that stems from limited human and financial resources, and a shortage of relevant expertise and skills. Several key agencies are generally understaffed. This situation is exacerbated by the growing complexity of work involved in designing and implementing sectoral and multi- sector decarbonisation and resilience policies. These challenges are more acute at provincial and municipal levels.

Also in short supply are the financial resources needed to augment governance capacities to work on climate change in the key agencies and for financing policy implementation and the underlying investments in the low-carbon and climate-resilient transition. One of the critical gaps underlying the shortage of finance is the lack of a comprehensive climate finance strategy to define the allocation of resources to support climate change work and to attract international funding and investment. Furthermore, there is a shortage of skills and capacity among the government departments, devolved administrations and private actors to prepare financeable project propositions.

Gaps and constraints in information and data

The need to improve the availability of credible data on current and projected greenhouse gas emissions and their mitigation potential is another challenge, and prompts wider concerns about the legitimacy of targets and policies. Addressing these challenges will require improvements to the collection of information and to the measurement of progress, including rigorous reporting and evaluation frameworks with clear common indicators.

Mistrust of public–private engagement

Fora to facilitate horizontal coordination between stakeholders have been established, including those to facilitate constructive engagement and discussion to build informal and personal

relationships (for example by the National Business Initiative). However, tensions remain and are often accompanied by calls for policy proposals to be changed and delayed. These tensions arise due to mistrust, difficulties in historical relationships, and questions around the pace, scale and form of policies. They exist both between and within government departments, state-owned enterprises, academic research centres, civil society and trade unions.

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While some issues are embedded in the general dynamics of the relationships between public sector and non-state actors in South Africa, many are related to the ways in which consultations are run: for example, concerns around continuity, and a lack of transparency on how feedback from stakeholders is dealt with. These issues are prevalent throughout South Africa’s political discourse and economic structure – but climate is a policy area where constructive interaction between the public and private sector is particularly important for making progress.

Opportunities to overcome barriers to climate governance

South Africa is now moving from climate policy planning to implementation, further exposing the challenges around climate change governance and making the need to address them increasingly urgent. Change in the leadership of the country and a new momentum in the discourse towards giving greater importance to climate and energy policy make it an opportune moment. The process of consultation on the draft climate change legislation recently launched by the Government, as well as the new draft Integrated Resource Plan (IRP), offer opportunities for discussing and implementing some of these improvements.

Recommendation 1: Align development of policies and strategies with the objectives of the nationally determined contribution (NDC)

Successful implementation of South Africa’s NDC requires that its objectives are strongly anchored in the National Development Plan, the Medium-Term Strategic Framework and developmental and management plans at provincial and city levels. It could be useful to include a requirement to mainstream climate change and to cooperate with other agencies in the performance goals and monitoring frameworks for each ministry and into the budget planning cycle, and for the performance metrics to include policy coordination and integration. The draft 2018 Integrated Resources Plan, which sets the future energy strategy (currently under

consultation), is an important step in the right direction, having integrated the NDC objectives in its scenarios and included a clear target for renewable capacity. Similarly, the reinstatement of the Renewable Energy Independent Power Producer Procurement Programme (REIPPPP) in 2018 was a welcome step. It is important that the Government’s commitment to these programmes and objectives is sustained and integrated into other sectoral policies.

Recommendation 2: Renew high-level commitment and empower key agencies through clear mandates

Successful implementation of climate policy requires renewed political commitment and leadership from the highest level and a unified approach from the Government. There needs to be a clear mandate for a lead agency entrusted with coordinating implementation and for each of the sectoral agencies to designate staff and resources and to implement policies, based on the existing work and lessons learnt from past experiences. A consideration should also be given to which agency is best suited to lead on the coordination of the implementation of the national climate change objectives, taking into account their technical expertise, political standing and availability of resources.

Recommendation 3: Launch a forum focused on implementing the NDC

Moving to implementation requires a transparent and continuous process focused on policy alignment and coordination, led by a strong government agency that has a clear mandate from the highest political level to coordinate this process. A system of common planning and

monitoring indicators or outcome templates could help facilitate coordination, backed up by an iterative process of reflection, learning and integration of lessons. Provincial and city

governments should have strong representation in this process. This forum should be chaired and convened at a high level (for example, ministerial), and include senior representatives from the private sector and civil society to discuss issues, challenges and coordination.

Recommendation 4: Develop a comprehensive finance strategy

Effective implementation of the NDC and the transition to low-carbon and climate-resilient development requires allocation of resources and strategic realignment of budgets.

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Development of the national climate finance strategy, as mandated by the White Paper, should be among the priority actions. Establishing a designated coordination mechanism on finance for NDC implementation could help align existing – and mobilise new – sources of funding. National government should also assist the provincial and municipal levels by providing guidelines and capacity-building on how to prepare projects. It should also make targeted funding available.

Recommendation 5: Frame the climate change discussion around developmental benefits and opportunities

Linking climate policy to poverty reduction objectives, clean energy access for communities and stimulation of new low-carbon industrial growth and innovation is key to leveraging buy-in and effective engagement across levels of governance, horizontally and vertically. In order to engage the relevant sectoral agencies in implementing the NDC, it is important to demonstrate the co- benefits of the interventions and opportunities, and positive synergies for advancing sectoral agendas, while addressing climate change.

Recommendation 6: Improve existing consultation and engagement fora

The effectiveness of the existing mechanisms for engaging stakeholders could be improved by expanding their membership (for example, by inviting the Inter-Ministerial Committee on Climate Change to meet with company CEOs), by engaging with the relevant sectors more consistently, and by making their participation in the main fora mandatory through direct, high- level mandates. Changing the mode and tone of engagement, and emphasising transparency in the Government’s methods of dealing with stakeholder feedback, would aid communication with stakeholders. It is also important that senior experts with a good understanding of business perspectives lead the engagement on the Government’s side.

Recommendation 7: Invest in strengthening relationships between stakeholders and the processes of interaction

Providing opportunities for all stakeholders to engage informally in non-governmental fora is key for breaking down the current barriers inhibiting public–private engagement. Spaces are needed where all parties can collaborate outside bureaucratic processes without being entrenched into formal positions of the constituencies they represent. This effort should be facilitated by a neutral broker who is trusted by both the Government and private sector. It should build on past experiences and focus on concrete implementation challenges.

National government and municipalities should also look for and cultivate ‘climate champions’

that could catalyse action. Furthermore, developing personal relationships that move away from

‘political lines’ to interactions as individuals, and investing in improving interaction processes, should be considered as part of key measures to improve the effectiveness of climate

governance. This would help overcome obstacles in horizontal and vertical coordination and stakeholder engagement. Practically, this could be done through participatory training or pilot projects that bring together experts from different sectors and stakeholder groups.

Recommendation 8: Improve data, information and public awareness

Developing and implementing the NDC and climate policies more broadly requires improving the data and information base. Continuing to strengthen public engagement to build awareness of climate change and related actions and policies, alongside the facilitation of climate activism, should form an important part of the NDC implementation strategy. Consideration should be given to improving ways of sharing expert information and research relevant for the low-carbon and climate-resilient transition, making it more accessible to the public sector and other

stakeholders.

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Abbreviations

ANC African National Congress BAU Business as usual

BUSA Business Unity South Africa

COP Conference of the Parties to the United Nations Framework Convention on Climate Change

Cosatu Congress of South African Trade Unions CSR Corporate social responsibility

DEA Department of Environmental Affairs DEROs Desired emission reduction outcomes

DPME Department of Planning, Monitoring and Evaluation DoE Department of Energy

FOSAD Forum of South African Directors General G20 Group of 20

GDP Gross domestic product

GIZ Gesellschaft für Internationale Zusammenarbeit (German Society for International Cooperation)

GW gigawatt

IDP Integrated Development Plan

IGCCC Intergovernmental Committee on Climate Change IMCCC Inter-Ministerial Committee on Climate Change IPAP Industrial Policy Action Plan

IRP Integrated Resource Plan

ISMO Independent System Market Operator LTAS Long-term adaptation scenario LTMS Long-term mitigation scenario

LULUCF Land use, land use change and forestry MDSF Medium-Term Strategic Framework MPA Mitigation Potential Analysis

MtCO2e Million metric tonnes of carbon dioxide equivalent

MW megawatt

NBI National Business Initiative

NCCA National Climate Change Adaptation NCCC National Committee on Climate Change NCCRP National Climate Change Response Policy

NCCRWP National Climate Change Response White Paper NDC Nationally determined contribution

NDP National Development Plan

NEDLAC National Economic Development and Labour Council NERSA National Energy Regulator of South Africa

NGO Non-governmental organisation

OECD Organisation for Economic Co-operation and Development PPA Power purchasing agreement

REIPPPP Renewable Energy Independent Power Producers Procurement Plan SALGA South African Local Government Association

SAFTU South African Federation of Trade Unions SoE State-owned enterprise

UNFCCC United Nations Framework Convention on Climate Change

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Introduction

In order to implement the Paris Agreement on climate change, a rapid shift to decarbonising economies and improving climate resilience is required. This brings new challenges to national climate governance, which is the ways in which decisions on climate change are taken and implemented in a country. While there are many dimensions to climate governance that are important, in this study we focus on the central question of how the state (as opposed to non- state actors) governs climate change and on the associated institutional arrangements and governance processes.

State climate governance arrangements and practices impact the ability of governments to set the overall direction for actions, coordinate implementation of those objectives, and mobilise other actors through incentives, constraints and normative influences. To implement the overall goals of the Paris Agreement and the specific objectives set in countries’ nationally determined contributions (NDCs), national climate governance mechanisms and practices need to be assessed and strengthened, with a clear understanding of existing weaknesses.

The objective of this policy report is to examine some of the emerging challenges in climate governance in South Africa and potential solutions, drawing out lessons for South Africa and for other countries facing similar challenges.

South Africa’s record in international and domestic climate change action

South Africa has often been at the forefront of international efforts to address climate change.

South Africa acceded to the United Nations Framework Convention on Climate Change (UNFCCC) in 1997 and ratified the Kyoto Protocol in 2002. In 2010, it was among the first emerging economies and developing countries to come forward with a voluntary emissions reduction pledge for 2020 under the Copenhagen Accord. The following year South Africa hosted the 17th Conference of the Parties (COP 17), which resulted in the launch of the Durban Platform for Enhanced Action. In 2015 South Africa submitted an intended NDC in the lead-up to the negotiations of the Paris Agreement.

Over the past two decades, South Africa has also adopted a range of national and sectoral policies, plans and strategies that aim at decarbonising the economy while meeting broad developmental objectives. To enable development and implementation of these policies the country created an elaborate system of climate governance, with several new institutions and consultative and decision-making processes (Figure 1 in Chapter 1 provides a timeline of climate- related policy by sector).

During the same period, South Africa has been through fundamental political and economic changes that have caused turbulence at times and have impacted all policy spheres, including climate change. Since the early 1990s, post-Apartheid South Africa’s economy has more than tripled in size and there has been large-scale investment in basic services (for example

education, electricity and water), increased provision of social services for the most vulnerable, and the establishment of important constitutional institutions, including the judiciary (OECD, 2017). However, since around 2013 South Africa has experience a period of stagnant economic growth, persistent unemployment, reduced investment, and continued widespread poverty and inequality.

These challenges have been compounded by the policy uncertainty and turmoil created during the period 2009 to 2018, when Jacob Zuma and the African National Congress (ANC) were in power. Towards the end of these nine-years, evidence emerged of widespread corruption and

‘state capture’¹ (see Public Protector of South Africa, 2016 and Bhorat et al., 2017). Cabinet

1 Transparency International defines state capture as “a situation where powerful individuals, institutions, companies or groups within or outside a country use corruption to shape a nation’s policies, legal environment and economy to benefit their own private interests” (Transparency International, 2014).

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reshuffles of ministers took place almost annually and there were frequent changes to the senior management of critical state-owned enterprises (SoEs). In many cases, these changes were intended to enable and facilitate access to resources with the aim of inserting facilitators into positions of influence to overcome barriers to corruption or to support specific private sector companies to gain access to lucrative procurement contracts (Bhorat et al., 2017). Current President, Cyril Ramaphosa, has referred to the ‘nine lost years’ (Hogg, 2019) while others call them the ‘Zuma years’ (for example, Grootes, 2019).

In 2018, Cyril Ramaphosa (previously Deputy President of South Africa) was elected President of the ANC and a few months later Jacob Zuma resigned as President of South Africa following pressure from the new ANC national executive committee. Subsequently Ramaphosa was elected President for the remainder of the term, and was re-elected in May 2019 for the start of his first official term.

The political turbulence and turmoil of the past 10 years caused by ‘state capture’ has impacted the design and implementation of many of South Africa’s climate change policies. While

President Zuma publicly supported climate action in international fora, action in the country was less evident during his last few years in office, which were characterised by delays in the

development and implementation of policies designed to reduce greenhouse gas emissions or adapt to climate change impacts: there were last-minute changes to the Renewable Energy Independent Power Producers Procurement Programme (REIPPPP), and delays to prominent climate change policies such as the carbon tax and carbon budgets.

In South Africa’s NDC submitted under the Paris Agreement in 2015, the country committed to reducing greenhouse gas emissions when compared with business-as-usual (BAU) by 34 per cent in 2020 and 42 per cent in 2025.² According to Climate Action Tracker, this target is equivalent to a 19–82 per cent increase on 1990 levels in 2025 (when emissions from land use, land use change and forestry [LULUCF] are excluded).

TheNDC is consistent with South Africa’s pledge under the 2009 Copenhagen Accord, which proposed emissions reductions below BAU levels, including LULUCF. But that target was developed in the early 2010s, a number of years before the Paris Agreement, and has not been updated since then. The target is not considered to be in line with the Paris Agreement (Climate Action Tracker, 2018).

Aims and importance of this study

As countries around the world move forward with implementing the Paris Agreement, many are reviewing their domestic governance frameworks and developing mechanisms that seek to enable their domestic transition to low-carbon and climate-resilient development (Averchenkova et al., 2017). Strong national governance is also essential in the context of ratcheting up

ambition on climate change under the Paris Agreement after 2020. This study undertakes an empirical analysis of national climate governance and policy implementation in a specific emerging economy, aiming to generate lessons for wider learning. While recognising the importance of overall political economy and policy uncertainty in South Africa, as discussed above, the purpose of the analysis is to aid policymakers and key stakeholders in South Africa in the identification of barriers and opportunities in existing governance structures to enhance implementation of climate policy. The lessons we identify are also relevant for other developing economies as they set out on the path to implement the Paris Agreement domestically.

Research method

Our analysis is based on perceptions of climate governance explored through 30 interviews encompassing the views of 32 of South Africa’s leading experts, from national and subnational government and sectoral agencies, the private sector, civil society and academia, who have been actively engaged in the national climate change debate and policy. The interviews were conducted between September 2017 and March 2018. Inputs from these key informants were

2 See https://climateactiontracker.org/countries/south-africa/

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complemented by a review of previous studies on South Africa’s climate policy. The interviews were complemented by analysis of the academic literature on climate change policy in South Africa, of the key national policy documents adopted or proposed for adoption, and of the main political developments up to May 2019. The Appendix provides more detail on the interviews.

Structure of the report

 Chapter 1 outlines the principal elements of South Africa’s national climate governance system.

 Chapter 2 reviews the main challenges facing climate governance in South Africa.

 Chapter 3 highlights opportunities for strengthening climate governance in South Africa in the future.

 Chapter 4 outlines recommendations for the future, aimed at South Africa primarily but applicable to other developing country economies.

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1. South Africa’s national climate change governance system

Figure 1. Timeline of climate-related policy by sector plus key political events, 2004–19

Source: Authors

This chapter provides an overview of the key features of national climate governance in South Africa, including the main institutions, mechanisms for their interaction, and relevant policy frameworks.

National climate change governance in South Africa is the product of more than two decades of policy evolution and has been shaped by an elaborate landscape of executive policies, strategies, regulations and institutions (see Figure 1).

The first document guiding climate change policy was the 2004 National Climate Change Response Strategy, which was followed by a comprehensive process of developing ‘long-term mitigation scenarios’ (LTMS). The LTMS process, which set out to formulate strategic options around South Africa’s mitigation potential, laid the basis for the content of South Africa’s pledge

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to the Copenhagen Accord in 2008 and later for its mitigation commitments in the NDC to the Paris Agreement. South Africa also prepared and submitted three national communications to the United Nations Framework Convention on Climate Change (UNFCCC), in 2003, 2011 and 2018, two national inventory reports, in 2014 and 2018, and two biennial update reports, in 2014 and 2018.³

The overarching national climate change framework, as well as the latest version of the objectives pledged under the NDC, including the ‘Peak, Plateau, Decline’ (PDD) emission trajectory, is set through the National Climate Change Response White Paper (NCCRWP) (Department of Environmental Affairs [DEA], 2011). It is also influenced by several pieces of legislation with specific provision for climate change (e.g. the Disaster Management

Amendment Bill, 2015) or implied provision (e.g. the National Greenhouse Gas Reporting

Regulations and Pollution Prevention Plans issued by the DEA under the National Environmental Management and Air Quality Act).

South Africa’s National Climate Change Response Policy

A key policy setting out the vision and overall policy framework is the National Climate Change Response Policy (NCCRP), which was set out in the National Climate Change Response White Paper (NCCRWP) and approved by Cabinet in 2011. The NCCRP arose from an extended participatory policy development process based on the country’s recent history of democratic engagement. This involved modelling and research activities as well as a suite of stakeholder engagements, reviews and parliamentary hearings. Its goals were informed by other national and international commitments, including the South African Constitution, the Bill of Rights, the National Environmental Management Act, the Millennium Declaration and commitments made under the UNFCCC. The NCCRP is supported by the overall strategic policy of the country, the National Development Plan (NDP) (2012).

In June 2018, South Africa launched public consultations on a draft National Climate Change Bill, which intends to put the key strategic climate change objectives, governance elements and policies into law (Government Gazette, 2018).

Long-term mitigation scenarios

The NCCRP built on the Cabinet-mandated long-term mitigation scenarios (LTMS) process, which took place between 2005 and 2008 and which identified packages of mitigation measures forming strategic options for the national mitigation potential. The LTMS was the first initiative in South Africa to develop a national view on mitigation potential and inform the position in the international negotiations (Trollip and Boulle, 2017).

The LTMS involved an inclusive stakeholder and technical process (e.g. Winkler, 2011) and, according to a recent study (Tyler and Gunfus, 2015), was perceived by many participants as having achieved its objectives. However, in 2010, some stakeholders started to push back, after the LTMS results were used as the basis for South Africa’s Copenhagen pledge and the concept of the ‘Peak, Plateau, Decline’ trajectory (Trollip and Boulle, 2017; Tyler and Gunfaus, 2015). The LTMS were meant to be an initial analysis to be updated later and were criticised for their lack of reliable data; some stakeholders felt that they were misled by the Government over the purpose of the process, which was not expected to lead to mandatory commitments (Tyler and Gunfaus, 2015). This discussion is still relevant in the context of the implementation of the NDC, and is considered in more detail in Chapter 3 below.

Flagship programmes

The NCCRP also established eight ‘Near-term Priority Flagship Programmes’, capturing the leading adaptation and mitigation actions and which serve as mechanisms for the DEA to work with other government departments. These ‘flagships’, as they are known, target climate change response public works; water conservation and demand management; renewable

3 See https://unfccc.int/BURs

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energy; energy efficiency and energy demand management; transportation; waste

management; carbon capture and sequestration; and adaptation research. They are designed, among other things, to target major emitting sectors and to test, develop and scale up a range of policy mechanisms and methods of implementation.

From these flagships, a number of key adaptation and mitigation policy mechanisms in South Africa have been developed, targeting different sectors. The Renewable Energy Independent Power Producer Procurement Programme (REIPPPP), for example, was scaled up as part of the renewable energy flagship programme.

Mitigation and adaptation

The NCCRP set out national priorities for climate change and was intended to build on existing mechanisms and policy proposals in relation to mitigation and adaptation. It names numerous strategies in relation to adaptation (e.g. identifying priority sectors and addressing adaptation interventions in sector plans) and mitigation (e.g. defining ‘desired emission reduction outcomes’

– or DEROs – for each sector and adopting a carbon budget agenda, as well as a carbon tax). It also provides for a Climate Change Response Monitoring and Evaluation System under the DEA.

Climate change policies at sectoral level

While there are a number of policies that operate across multiple sectors, there are also those that are targeted at avoiding emissions or supporting more specific sectors. The development of these sectoral level policies in South Africa is skewed by the greenhouse gas emissions profile of the country, with high-emissions sectors having more developed climate policy landscapes (see Figure 1).

A focus on the energy sector

The majority of substantive national-level policies to date have been focussed on the energy sector and were developed between 2004 and 2010. This includes the introduction of an overall energy efficiency strategy in 2005, the introduction of a non-renewable electricity levy in 2009, and the inclusion of a carbon constraint for the first time in the 2010 Integrated Resource Plan (IRP 2010) for energy.

However, since 2010/11 some of the key climate change and low-carbon energy policies have stalled. This includes updates to the IRP, delays in approval of the carbon tax and development of policies targeting other renewable energy (such as small-scale generators). This situation is partly due to the political obstruction during the ‘state capture’ years (see Introduction). An example of this influence can be seen in the IRP process and its impact on the uptake of renewable energy (see Box 1 below).

More variation in industry, waste, agriculture and transport

In other sectors too (industry, waste, agriculture and transport), the policy development process relating to climate change-specific policies has been varied and sporadic. For example, even though industry has received more attention than other sectors from policymakers, it has taken a while to develop and implement policies. The substantive policy developments for industry since the NCCRP and NDP have been related to the National Greenhouse Gas Emission

Reporting Regulations and the National Pollution Prevention Plan Regulations, both promulgated in 2017. These require covered sectors to report greenhouse gas emissions through the national system and develop mitigation plans, with the first compliance periods in 2018. The Emission Reporting Regulations and the Pollution Prevention Plan Regulations are both key elements of the national climate change mitigation system developed by the Department of Environmental Affairs and approved in 2015. They feed into the broader climate change policies under the NCCRP, including the development of the carbon budgets and the management of the carbon tax (see Box 2), which are also targeted at industry.

For the sectors with lower greenhouse gas emissions, policy development and implementation has been slower despite there being flagship programmes allocated to each. For example, there

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is not yet an approved overarching climate change strategy for agriculture, with both the sector plan and the climate-smart agriculture strategic framework still in draft form and undergoing consultation. The waste sector has also not seen any major climate change-specific policies developed, with only a reference included in the overall Waste Strategy since 2009. Neither the waste nor agriculture sector is currently covered by the carbon tax (introduced in 2019). To support mitigation, these sectors are eligible to generate and sell carbon offsets under the mechanism introduced by the Carbon Tax Bill, potentially raising a new finance source for mitigation action.

Transport, which is the fourth largest sector in terms of greenhouse gas emissions, also does not have an overarching national strategy focusing on mitigation actions. Policies in the sector to date have focussed on using fiscal instruments from the National Treasury, including an

environmental levy on new car sales (2010) and the addition of a carbon tax component to the fuel levy (2019), but the effectiveness of these without supporting policies is questionable (for example see Curran, 2019). Broader national policies to support public transport, extend electrification to vehicles or support modal shifts from road to rail do not currently exist. The Biofuels Regulatory Framework from the Department of Transport (introduced in 2014) is still in draft form, and it is not clear if it will be approved in 2019.

Box 1. The REIPPPP, IRP, Eskom and political interference

The Renewable Energy Independent Power Producers Procurement Programme (REIPPPP) is widely acclaimed as one of the most successful cases of competitive tenders for grid-connected renewable energy by independent power producers. The design of the programme managed to attract extensive private investment and engender large falls in the energy tariffs (Eberhard and Naude, 2017). To date, it is the largest and most successful greenhouse gas mitigation measure implemented in South Africa (Trollip and Boulle, 2017). From 2015 to 2018, however, it stalled, creating policy uncertainty and harming South Africa’s climate change policy

credibility.

Source: Authors

Following widespread electricity supply disruptions in South Africa in 2007 and 2008, a process of investment in new generation capacity was started. This new capacity was guided by the Integrated Resource Plan for Energy (IRP), approved in 2011 (IRP 2010). The IRP identified a mix of generating technologies, including 6 gigawatts (GW) of new coal, 18 GW of renewables (solar and wind), and 9.6 GW of nuclear.

To build the renewables capacity a public–private partnership initiated by the National Treasury, Department of Energy, National Energy Regulator of South Africa (NERSA) and Eskom, the vertically integrated state-owned electricity sector monopoly, was established. This was known as the REIPPPP and was a first for South Africa in the electricity sector.

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The initial rounds of the REIPPPP went mostly according to design, with some learning and improvements. The first round of bidders reached financial close in 2012. Prices were expectedly high due to technology and transaction costs in a new system. Subsequently in rounds 2 to 4 (which closed in 2015), the bidding costs fell steeply to eventually be competitive with other generation technologies (see Eberhard and Naude, 2017).

At the same time, the IRP process was scheduled to be updated every two years. This was done in both 2013 and 2016. While IRPs were produced at both times, the outputs were contradictory with each other. The IRP 2013 update called for greater allocation to renewable energy than did the IRP 2010, while the IRP update in 2016 prioritised investment in nuclear energy. Over the IRP update periods there was high-level support from President Zuma and senior ministers (e.g. the Minister of Energy) for a large-scale nuclear development based on the IRP 2010 (Rennkamp and Bhuyan, 2016). Due to political wrangling neither of these updates was approved, leaving the IRP 2010 as the official energy policy guiding the sector (Yelland, 2016).

The political influence over this period is also evident at Eskom. From 2007 to 2018, Eskom had 10 chief executive officers, six chairpersons, and multiple changes at senior management levels (Kazeem, 2019). The senior management team (CEO and CFO) active between 2015 and 2018 consistently championed nuclear and refused to sign purchase agreements with renewable energy providers (Baker, 2017).

Furthermore, Eskom itself had been in a crisis, with a combination of mismanagement, corruption and lack of investment; both the CEO and CFO were implicated in ‘state capture’

(Public Protector, 2017). This crisis resulted in a doubling of production costs and falling

revenues due to slower economic growth, creating the need to borrow extensively (BBC, 2019).

As of early 2019, Eskom owes nearly R420bn (US$30bn) (nearly 15 per cent of South Africa’s national debt). To be eligible to continue to operate, Eskom requires frequent bailouts from the Government, which, as its sole shareholder, is guaranteeing more than half the debt. As evidence of the crisis in 2018 and 2019, South Africa experienced widespread electricity supply disruptions (‘load shedding’), with nearly 4 GW needing to be shed at certain points.

Following the inauguration of a new President of South Africa and a change in management at Eskom, the outstanding agreements were signed. The next IRP update (IRP 2018) has

undergone public consultation but it has not yet been approved.

Adaptation and resilience

Polices on adaptation and resilience have had little focus to date, with priorities skewed towards mitigation action, but some have been put in place latterly following publication of the National Climate Change Response Policy. The Long Term Adaptation Scenarios (LTAS) were released in 2013 and have subsequently been used to inform the policy planning process across different sectors, including water, agriculture and forestry, health, fisheries and biodiversity.

While production of the LTAS was a comprehensive process in terms of the stakeholders it included, these scenarios and findings have yet to be translated into an overall adaptation strategy. A draft National Climate Change Adaptation (NCCA) strategy was released in 2017 for public comment, but has not yet been approved by the Cabinet.

Horizontal and vertical dimensions of climate change governance

To provide a comprehensive response to governing climate change it is important that a range of supporting policies be developed for action in each sector. Policies alone are, however, not enough. As the National Climate Change Response White Paper (NCCRWP) recognises, to ensure sustainable development and a just, managed transition to a low-carbon economy and society these policies need to be aligned both vertically (from national to local levels) and horizontally (between national departments) to achieve common goals. This section discusses the approach South Africa has adopted to manage this coordination.

The NCCRWP sets out an obligation for all government departments and state-owned

enterprises to align their policies, strategies and regulations with the content of the White Paper.

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The design and development of domestic climate change policy in South Africa is led by the national government with the Department of Environmental Affairs (DEA) (see Figure 2).

Figure 2. Responsibilities for design, support and implementation of domestic climate change policy in South Africa

Source: Authors

The DEA is the main coordinating agency responsible for establishing overall targets and

frameworks for policy implementation. The DEA is also responsible for representing South Africa in the UNFCCC process, for coordinating climate change policy and action, and for tracking interventions and progress for the achievement of South Africa’s NDC. The DEA has led on the development of overarching climate change policies and draft legislation (including the Draft Climate Change Act and the National Greenhouse Gas Emission Reporting Regulations).

The development and implementation of the policies required to meet the targets set out in the NCCRP intersect with, and crosscut, many of the priorities and responsibilities of other

government departments.⁴ These departments play key roles in the governance of climate change and are essential stakeholders in supporting the DEA in designing, and

mainstreaming/implementing climate change-relevant policies.

For example, the Department of Energy (DoE) is responsible for long-term energy policy and planning, including through the Integrated Resource Plan (IRP), which was most recently revised in August 2018, as discussed in Box 1 above. Since the energy sector is responsible for the largest share of South Africa’s carbon emissions (National Treasury, 2013), the IRP has a fundamental role in determining the country’s emissions trajectory.

4 For example, the Department of Energy (DoE), Department of Transport (DoT), Department of Agriculture, Forestry and Fisheries (DAFF), National Treasury (NT), Department of Economic Development (EDD), Department of Trade and Industry (DTI), Department of Science and Technology (DST), and Department of Public Enterprises (DPE) – see Figure 2. Department names correct as of 5 June 2019.

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The National Treasury, meanwhile, has led on the development of the economy-wide carbon tax proposal provided for under the NCCRP with the intention to “create the necessary price signals and change relative prices so as to encourage behavioural changes in producers and consumers over time” (National Treasury, 2013).

Institutions given an explicit role in mainstreaming climate-resilient development and policy agendas under the NCCRP include the National Disaster Management Council, the Forum of South African Directors-General clusters, and the Parliamentary Portfolio Committees, especially those on Water and Environment Affairs; Energy; Agriculture, Forestry and Fisheries; Trade and Industry; Mining; Science and Technology; and Transport. There are also other institutions that are crucial implementers of climate policies, including SoEs (such as Eskom and Transnet), as well as provincial governments, metropolitan municipalities (for example the City of

Johannesburg and City of Cape Town), and local governments.

The NCCRP, including through the flagship programmes, gives many of these different

departments roles to contribute to realising climate commitments. Most sector departments, especially those targeted in the NCCRP, have developed some form of climate change plan and strategy or have taken action to mainstream climate change into other policies and plans. As discussed earlier this has, however, happened at different speeds and scales.

Ensuring coherent policy formulation and implementation both vertically and horizontally remains challenging due to the fragmented nature of responsibility for climate policy. In implementing policy commitments, the DEA coordinates with other relevant government departments and with other levels of government to integrate and align sector-related climate change strategies under the NCCRP and the NDCs with sectoral plans. The DEA often relies on contracting independent consultants to complete its work (e.g. through the Energy Research Centre at the University of Cape Town and private sector consultancies), as well as some parastatals and science councils. This reliance on external consultants has been a longstanding challenge – one that was highlighted in the National Communications and LTAS processes, among others. Furthermore, the DEA in the past several years has been relying significantly on financial and technical support from the German development agency, GIZ.

Despite naming multiple mitigation and adaptation mechanisms and regulatory and economic instruments to operationalise climate policy across different government departments, the NCCRP does not establish a clear relationship between different elements within the policy. In some cases, this has led to a lack of clarity surrounding how the policies will be jointly

implemented and aligned across sectors. Further, despite the crosscutting nature of climate change policy, outside of the DEA in other government departments there are not always people with climate change-specific roles. Rather, those that manage departmental climate portfolios often do so alongside other functions.

An example of weaker coordination and lack of coherence is evident in the case of two of the most prominent climate policies developed to date, the carbon tax and the carbon budgets.

These two policies were developed somewhat independently although often in parallel, leading to confusion and delays, as discussed in Box 2 below.

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Box 2. Coordination challenges in aligning the carbon tax and carbon budget South Africa’s most prominent climate change mitigation policies, outlined in the NCCRP and the National Development Plan (NDP), are the carbon tax and the carbon budgets. While these two policies aim to complement each other, they have been developed separately.

Source: Authors

This parallel process has arisen due to the responsibility for development for the carbon tax lying with the National Treasury, while the DEA has responsibility for the carbon budgets. The Treasury started its process in 2010 with the release of a discussion paper on the carbon tax.

This paper was followed by the NCCRP and the NDP, which indicated that the carbon tax was a preferred option. However, the NCCRP also provided for the development of carbon budgets, and responsibility for this was allocated to the DEA.

The carbon tax option progressed with discussion papers on the design of the carbon tax and the offsets mechanism in 2013 and 2014 respectively, outlining the covered sectors, tax rates, allowance rates and escalation rates. A start date of January 2015 with the first phase ending in 2020 was announced.

In 2014, the DEA began to develop South Africa’s broader climate change mitigation system, starting with the publication of the Mitigation Potential Analysis (MPA) and the approval of the mitigation system in 2015. However, the policies required to support the system and establish the DEROs were not in place; two essential regulations were then passed in 2017, with

compliance set for 2018.

During the DEROs development period, the carbon tax was postponed three times and a new start date set twice. The Treasury said each delay was to allow further consultation and support alignment with the DEROs (Curran, 2018).The carbon tax was finally signed into law to start in June 2019, while the DEROs entered a voluntary phase ending in 2020 with no compliance requirements before then.

While there was an update in the approved Carbon Tax Bill in an attempt to align the two policies, this was not substantive. The alignment consisted simply of the introduction of a new allowance for covered entities that participate voluntarily in the first phase of the DEROs process (until 2020). Most of the other features of the carbon tax were the same as the first proposal, made in 2013 (see Curran, 2018).

Due to the lack of horizontal coordination between the National Treasury and the DEA, the implementation of the carbon tax was delayed for five years in total. During this period, there was much uncertainty for private sector and state-owned enterprises due to be subject to both the tax and the budgets.

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Fora for internal coordination of climate policy

The main fora in which the DEA can shape internal government integration include the Inter- Ministerial Committee on Climate Change (IMCCC), the Intergovernmental Committee on Climate Change (IGCCC), and the Forum of South African Directors General (FOSAD) – see Figure 3.

Figure 3. Fora for coordination of climate policy within South Africa

Source: Authors

The remits and relationships of each national level-forum are as follows:

 The Inter-Ministerial Committee on Climate Change (IMCCC) is the climate change coordination committee at executive level. Chaired by the Minister of Environment, it is a sub-committee of the full Cabinet, composed of ministers that have a stake in climate change policy.

 The Intergovernmental Committee on Climate Change (IGCCC) was established to operationalise cooperative governance and brings together relevant national and provincial departments (and ‘organised local government’). The DEA coordinates the IGCCC and thus the IGCCC is a key forum through which the DEA attempts to support the alignment of sectoral policies with national climate change policies and

commitments and ensure sectoral policies and strategies do not contradict one another.

 The Forum of South African Directors General (FOSAD) was established to coordinate policy development and implementation between the most senior civil servants from each ministry. FOSAD is a deliberative and consultative body that aims to ensure cross- departmental alignment of priorities, monitor implementation of Cabinet priority programmes, and provide technical support to ministerial departments.

The IMCCC and the IGCCC sub-committee are given responsibility for the development and oversight of the flagship programmes. The DEA also consults bilaterally, including with other government departments. Ultimately, however, the other government departments are on the same horizontal tier of government as the DEA, and so the DEA often has to rely on soft power to collaborate with other departments and ensure alignment, such as through the FOSAD, or by collaborating with sectoral ministries on the drafting of funding proposals.

The DEA is also tasked with facilitating vertical coordination to support the implementation of climate policy at municipal and provincial levels. All tiers of government have to adhere to overall national policies, but provincial governments in South Africa have their own legislative and executive branches while municipalities are governed by municipal councils. Therefore, implementation of national policies has to align with provincial and municipal government

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budgets and rules. The nine provinces (see map in Figure 3), as well as municipal governments, in the form of local government associations, participate in the formation of climate policy through the IGCCC, and representative bodes such as the South African Local Government Association (SALGA).

While South Africa technically has an elaborate system for vertical and horizontal coordination, the effectiveness of coordination and the level of integration remain low. All provinces have developed climate change strategies and plans, although only a few have mainstreamed climate change into other plans and strategies – and this to varying degrees of effectiveness. Climate change strategies, plans and mainstreaming are more limited among district and local municipalities. In terms of coordination, several provincial climate change fora have been established, in the Northern Cape, Western Cape, Eastern Cape, KwaZulu-Natal and Gauteng.

However, the First Annual Climate Change Report (DEA, 2016) highlighted that the provincial fora in some provinces are not functional.

Integration across other levels also remains limited. Large provinces and metropolitan cities have generally been proactive but slow in developing climate change strategies and plans, including the City of Cape Town’s Climate Change Strategy (approved in 2017), the City of Tshwane Climate Response Strategy (approved in 2018) and the Durban Climate Change strategy (approved in 2014). Progress towards developing strategies and implementing policies within smaller cities and local governments is less advanced and faces challenges due to capacity constraints and limited resources (see Chapters 2 and 3 for discussions).

Private sector and civil society participation in climate governance

The private sector, state-owned enterprises, academic research centres, civil society and trade unions are other major players in climate governance in South Africa – see Figure 4.

Figure 4. Stakeholder engagement pathways in South Africa’s climate governance

Source: Authors

South Africa has a comprehensive and robust stakeholder engagement process through which every climate change-related policy must pass. The extensive consultation processes often culminate in acrimony, conflict and threats of legal challenges or litigation.

The primary mechanism established by government for more continuous coordination and consultation on climate change activities with national stakeholders is the multi-stakeholder National Committee on Climate Change (NCCC), overseen by the DEA. The NCCC meets once a quarter and is attended by stakeholders from other government departments, business

(including key business associations, as discussed below) and civil society. The work of the NCCC is supported through several technical working groups, which focus on particular policy aspects (e.g. national adaptation strategy or mitigation). The NCCC provides feedback to the IGCCC to support coordination, but has experienced some challenges (see Chapter 2).

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Other fora through which climate policy is discussed include the multi-stakeholder forum provided by the National Economic Development and Labour Council (NEDLAC), where policies are discussed and deliberated between business, labour and community representatives. The outcome of the deliberations are fed back to the relevant ministries for consideration in the design of the policies. The inputs from NEDLAC have been submitted for all major climate change policies, including the NCCRP, Carbon Tax Bill, and the draft IRP 2019.

The private sector and SoEs

The primary mechanism for government to interact with business is through the NCCC.

Individual companies and associations may also be represented or consulted at the project level (e.g. through the flagship programmes) and the private sector lobbies the Government directly.

Business associations and other private sector representative groups may also provide additional forms of climate governance, e.g. by promoting and guiding private sector action on climate change and by providing supportive networking facilities and discussion platforms (Never, 2011).

The private sector both shapes, and is greatly impacted by, climate mitigation and adaptation governance and policy. Through the development of emerging business opportunities, alongside corporate social responsibility (CSR) activities, the setting and implementation of energy

reduction plans and targets, and providing access to alternative funding mechanisms (e.g. the Global Environment Facility), the private sector is a route through which climate change mitigation and adaptation can be implemented and upscaled (see Figure 2 above). Decisions surrounding the DEA carbon budgets and the National Treasury’s carbon tax proposals,

meanwhile, directly target segments of the private sector, including high emitters. The private sector is therefore a major stakeholder in climate change governance and its constructive engagement is fundamental to maximising opportunities, as well as ensuring the practicability, acceptability and buy-in of policy decisions and interventions.

The private sector is represented in consultative climate fora both by large individual companies and through business associations. Some of the most notable private sector groups in the climate governance sphere include the National Business Initiative (NBI), Business Unity South Africa (BUSA), the Energy Intensive User Group and the Chamber of Mines.

Generally and publicly, private sector and state-owned enterprises are supportive of climate change objectives and there is little dispute over the importance of addressing climate change.

Yet there are significant differences in the positions among the players when it comes to the speed and means of action and reaction to specific policies. The NBI, which is a voluntary

coalition of South African and multinational companies with members from the financial sector, renewable energy and service industries, says it is committed to “working towards sustainable growth and development… and the shaping of a sustainable future through responsible business action” (NBI, 2019). The NBI has been a private sector actor supportive to ambitious action on climate change. It has formed several partnerships with the Government and has been

instrumental in helping bridge public and private tensions around climate policy (see Chapter 2).

BUSA, the Energy Intensive User Group and the Chamber of Mines, which represent the interests of large emitters and industries that are likely to be affected by climate change policies, have taken a different approach. These bodies have been lobbying against specific policy proposals, arguing for changes and often delays to implementation. For example, they have consistently raised concerns against the carbon tax and its alignment with the carbon budgets policy, requesting support for increased operation costs due to rising input costs, and have promoted technology investment over other policies (for examples see Bisseker, 2019 and BUSA, 2018).

The private sector is also actively employed in the design and implementation of climate change projects, through significant dependence on the use of a relatively small pool of consultants to design and implement various climate governance strategies and to develop decision-making tools. Often the same consultants are employed by individual companies and industry

associations to develop and assess the impacts of climate policy on their operation, or represent them in consultative fora.

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Civil society actors and international donor communities play an important role in the design and delivery of climate policy and action, including through participation on advisory panels and steering committees, and through capacity-building and lobbying for the interests of more vulnerable groups, including through the NCCC. In support of this function, civil society provides additional consultation fora (e.g. through the Adaptation Network) and, again, civil society may directly lobby the government.

Non-governmental organisations (NGOs) and other development actors (e.g. the German development agency, GIZ – which, among others, has played a major role in supporting DEA on climate policy) also support delivery of climate projects at a technical and programme level and are key actors in the downscaling and mainstreaming of climate policy into local development activities. Civil society may also provide capacity-building support to increase access to climate finance, including for more vulnerable groups. The broader capacity of civil society to engage on climate change and to influence decisions seems to be generally weaker than that of the private sector. Limited resources and capacity curtail their ability to engage in all the fora.

Overall, our stakeholder interviews⁵ revealed little coordination and cooperation among different non-state actors. This is in part due to a high level of competition for consulting contracts

among consulting companies and research institutions. As a result, many actors with the highest levels of knowledge, a supportive stance on climate change policy and high levels of personal commitment miss out on the opportunity to cooperate and be more effective in pushing for a more ambitious climate policy.

Trade unions

South Africa has a long history of trade union engagement and activism. Most of the major trade unions and trade union bodies in South Africa, including the Congress of South African Trade Unions (Cosatu) and the South African Federation of Trade Unions (SAFTU), recognise climate change as a major issue and support a just transition to a low-carbon economy (SAFTU, 2017; Cosatu, 2019). They have participated in the design of policies on behalf of their members through fora such as NEDLAC, Parliament and other consultations and have extensive lobbying power with the national government, above that of other civil society organisations; indeed, many of their former leaders now hold senior government positions, including President and Minister of Energy, and as Members of Parliament.

In recent years, the unions have built resistance to the development of more ambitious climate policies due to their implications for sectors where many of their members are employed (including coal mining, heavy industry, electricity generation and road transport). Concerns around job losses, rising electricity prices, or implications for fuel price increases have led unions to call for changes or delays to policies, including the carbon tax and the REIPPPP (Omarjee, 2019). For example, trade union court action delayed the restarting of the REIPPPP as the National Union of Metalworkers of South Africa and others attempted to prevent the signing of the outstanding PPAs that had been stalled since 2015 (NUMSA, 2019). That case was lost and the contracts signed, but there have been calls for other policies to be reconsidered, including the carbon fuel levy.

5 See Appendix for an overview of the interview process we carried out with 30 experts on climate policy in South Africa.

Governance of climate change policy: